Justia Kansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the decision of the court of appeals granting the State's motion to dismiss Defendant's appeal of the denial of his motion to correct an illegal sentence based on the calculation of his criminal history, holding that because Defendant failed to challenge the State's motion for involuntary dismissal of his case as moot, dismissal correct. Defendant was convicted of a drug offense and sentenced to a term of imprisonment based on a criminal history classification of A. Defendant later filed a motion to correct an illegal sentence, which the district court denied. Defendant appealed. Thereafter, the State sought dismissal on the grounds that Defendant had completed his sentence and the appeal was moot. The court of appeals granted the motion when Defendant did not challenge that motion. The Supreme Court affirmed, holding that Defendant did not preserve his argument for appeal. View "State v. Sykes" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that the appeal was moot. In 2011, Defendant pleaded guilty to aggravated burglary. The district court sentenced Defendant to a term of imprisonment based on a criminal history classification of B. Defendant later filed a motion to correct an illegal sentence, arguing that his criminal history classification was incorrect, making his resulting sentence illegal. The district court denied the motion. Defendant appealed. The State moved to dismiss the appeal, arguing that the case was moot because Defendant had completed his sentence. The court of appeals granted the motion and dismissed the appeal as moot. The Supreme Court affirmed, holding that because Defendant failed to offer the court of appeals any challenge or response to the State's motion to dismiss, Defendant failed to preserve any argument for appeal. View "State v. Mayes" on Justia Law

Posted in: Criminal Law
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The Supreme Court remanded this case to the court of appeals for consideration of State v. Roat, __ P.3d __ (No. 113,531, this day decided), holding that because the court of appeals did not have the advantage of Roat when it dismissed Defendant's appeal as moot, remand was required. In 2013, Defendant pleaded no contest to one count of criminal threat and two counts of assault against the victim. The district court later revoked Defendant's probation. While Defendant was serving his second round of probation, he committed acts that led to his later conviction for criminal threat. Defendant later filed Kan. Stat. Ann. 60-1507 motion, which the court summarily dismissed. Defendant appealed, characterizing his original motion as both a section 60-1507 motion and a motion to correct an illegal sentence. The court of appeals dismissed the appeal as moot because Defendant had completed his sentence. The Supreme Court remanded the case, holding that, under Roat, the completion of a sentence does not necessarily render a case moot, and courts must carefully analyze whether dismissal would affect an asserted right. View "State v. Ward" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's appeal of the district court's denial of his motion to correct an illegal sentence, holding that the completion of a sentence does not necessarily render a case moot but that Appellant's appeal became moot as a consequence of the expiration of his sentencing conditions. Defendant pled guilty to making a criminal threat and was sentenced to a term of imprisonment with a probation period. His probation was later revoked, and the prison term was imposed. The next year, Defendant pled guilty in a separate case to drug offense. The district court sentenced Defendant to thirty-four months in prison. Defendant later filed a motion arguing that both sentences were illegal because the court had improperly calculated his criminal history. The district court denied the motion. The court of appeals dismissed Defendant's appeal. The Supreme Court affirmed, holding (1) a case is moot when a court determines it is clearly and convincingly shown that the actual controversy has ended, that the only judgment that could be entered would be ineffectual for any purpose, and that it would not have an impact on any of the parties' rights; and (2) under the circumstances, Defendant's appeal was moot. View "State v. Roat" on Justia Law

Posted in: Criminal Law
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The Supreme Court dismissed the appeal brought by Defendant challenging the district court's decision to classify his 1974 Colorado conviction for second-degree burglary as a person felony when determining his criminal history score prior to sentencing him for methamphetamine possession, holding that the appeal was moot. Defendant filed a motion to correct an illegal sentence, which the district court denied. On appeal, Defendant argued that his Colorado conviction was improperly classified. The court of appeals disagreed. Before the Supreme Court heard this appeal, Defendant fully served his prison sentence and the applicable period of postrelease supervision. The Supreme Court dismissed the appeal, holding that the issue raised before the Court was moot and that none of the exceptions to the mootness doctrine applied. View "State v. Tracy" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the district court denying Defendant's postsentencing motion to withdraw his guilty plea after it found that the record conclusively showed Defendant's plea was knowing and voluntarily made, holding that the district court correctly denied the motion. Defendant pled guilty to premeditated first-degree murder, aggravated robbery, felony theft, forgery, and misdemeanor theft. In his motion to withdraw his guilty plea, Defendant argued that he had a mental illness that rendered his plea involuntary. The district court denied the motion. On appeal, Defendant argued that the district court erred in denying his motion without an evidentiary hearing and that his counsel was ineffective because he did not have Defendant undergo a mental health evaluation. The Supreme Court affirmed, holding (1) Defendant failed to show the manifest injustice necessary to allow him to withdraw his plea; and (2) counsel's decision to forgo a mental health evaluation did not constitute deficient representation. View "State v. Adams" on Justia Law

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The Supreme Court reversed the judgment of the district court ordering Defendant to pay $5,000 in restitution, holding that Defendant met his burden to present some evidence of compelling circumstances to prove the restitution was unworkable. Defendant pleaded guilty to one count of capital murder. The district court sentenced Defendant to prison for life without parole and ordered him to pay restitution but without explicitly ordering payments from prison. The district court judge who had previously found Defendant indigent stated, "[a]nd I understand with the restitution of 5,000 that it will never be paid." The Supreme Court reversed, holding that, under the circumstances, the district court abused its discretion in ordering restitution. View "State v. Tucker" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions for two counts of rape of a child under the age of fourteen, holding that the court of appeals erred in concluding that rape of a child has no mental culpability requirement so Defendant's intent was irrelevant. On appeal, Defendant argued that K.H., the alleged victim, raped her and that she continued the sexual contact because K.H. was blackmailing her and she had a mental disease or defect. The court of appeals concluded that whether K.H. forced the sexual encounter was irrelevant. The Supreme Court reversed, holding that even if Defendant's rape defense was not relevant to a mental culpability requirement, it was relevant to the actus reus requirement. The Court remanded the case to the district court for a Van Cleave hearing to determine whether defense trial counsel was ineffective for failing to argue that the State never established the voluntary act requirement. View "State v. Dinkel" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated its judgment reversing the judgment of the court of appeals, which reversed the district court's ruling granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that the district court's judgment is affirmed in accordance with the decision of the United States Supreme Court. The district court determined that the officer lacked reasonable suspicion of illegal activity when he stopped the vehicle, making the seizure of Defendant a violation of his Fourth Amendment rights. The court of appeals reversed. The Supreme Court reversed the court of appeals. The United States Supreme Court granted the State's petition for a writ of certiorari and reversed, holding that the investigative traffic stop was reasonable under the Fourth Amendment. Accordingly, the Kansas Supreme Court vacated its judgment reversing the court of appeals and remanded for further proceedings. View "State v. Glover" on Justia Law

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The Supreme Court vacated its decision reversing the judgment of both the court of appeals and district court concluding that the Immigration Reform and Control Act of 1986 (IRCA) did not preempt Defendant's prosecution for identity theft and making false information, holding that, in accordance with the decision of the United States Supreme Court on certiorari in this case, Defendant's prosecution was not preempted by the IRCA. A district court judge found Defendant guilty after denying his motion to dismiss charges based on representations in his W-4 employment form. On appeal, Defendant argued that the IRCA preempted identify theft and making false information prosecutions. The court of appeals affirmed. The Supreme Court reversed, concluding that IRCA preempted Defendant's prosecutions. The United State Supreme Court granted certiorari and held that state law prosecutions for identity theft and making false information were not preempted by the IRCA. The Kansas Supreme Court affirmed in accordance with the decision of the United States Supreme Court. View "State v. Morales" on Justia Law